Jeanne M. Trent - Page 2

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          6015(g)(2) and whether application of petitioner’s overpayments,            
          including earned income credits, for subsequent years violates              
          section 6015(e)(1)(B).  In his reply brief, respondent states:              
          “If the Court finds that petitioner is not barred from raising              
          I.R.C. sec. 6015 by the doctrine of res judicata, then respondent           
          concedes that petitioner is entitled to relief from joint and               
          several liability under I.R.C. sec. 6015(f).”  Unless otherwise             
          indicated, all section references are to the Internal Revenue               
          Code in effect for the year in issue.                                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Los Lunas, New Mexico, at the time she                
          filed the petition in this case.  From May 1981 to November 1996,           
          petitioner was married to S. Trent.  Petitioner and S. Trent had            
          2 minor children during the year in issue.  Petitioner had access           
          to the couple’s joint checking account and paid bills from the              
               S. Trent was the sole proprietor of a motorcycle repair                
          shop, Paradise Cycles (Paradise).  In 1993, petitioner began                
          working for Paradise as an office manager.  Petitioner answered             
          the telephone, picked up motorcycle parts, prepared a general               
          ledger, reviewed receipts and expenditures, and paid bills.  The            
          general ledger contained records of checks, expenses, and income.           

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